Amendments to Tax Treaty between Ukraine and the Netherlands

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On 15 June 2021, the Protocol amending the 1996 tax treaty between Ukraine and The Netherlands (the “Treaty”) was ratified by the Parliament of Ukraine.

The key amendments include, in particular:

  • Tax rate for dividends for qualifying shareholders increases from 0% to 5%;
  • Tax rate for interest increases from 2% to 5%;
  • Tax rate for royalty for copyright, trademark, know-how, etc increases from 0% to 5%;
  • Exchange of information between the tax authorities will intensify; and
  • Further limitation of the application of the benefits of the Treaty.  No benefits provided by the Treaty will be granted if the main purpose of any transaction or arrangement was to directly or indirectly obtain such benefits.

For further information please contact Dmytro Ivanusa,

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